1.1. Who are we?

We are Classmethod (Thailand) Co., Ltd., a corporation having its registered office at 213/4 Asoke Towers, Room B, 5th Floor, Sukhumvit 21 Road, Klongtoey-Nua, Wattana, Bangkok 10110.
We have the following affiliate companies (“Our Affiliates”):
- Classmethod, Inc., a corporation having its registered office at 26F Hibiya Fort Tower 1-1-1 Nishishimbashi Minato-ku, Tokyo 105-0003
- Classmethod (Europe) GmbH, a corporation having its registered office at Krausenstraße9-10, 10117 Berlin, Germany
- Classmethod Canada Inc., a corporation having its registered office at 16th Floor, 555 Burrard Street, Vancouver, BC, V7X 1M8
- Annotation, Inc., a corporation having its registered office at 26F Hibiya Fort Tower 1-1-1 Nishishimbashi Minato-ku, Tokyo 105-0003
- Prismatix, Inc., a corporation having its registered office at 26F Hibiya Fort Tower 1-1-1 Nishishimbashi Minato-ku, Tokyo 105-0003
- Nextmode, Inc., a corporation having its registered office at 9F Iwamotocho Twin Building 2-5-12 Iwamotocho Chiyoda-ku, Tokyo 101-0032
- Classmethod (Europe) GmbH, a corporation having its registered office at Krausenstr. 9-10, 10117 Berlin, Germany
- Classmethod Korea Co., Ltd., a corporation having its registered office at #1116, Saenggak Gongjang, Building A, 150 Yeongdeungpo-ro, Yeongdeungpo-gu, Seoul 07292, Republic of Korea
- Classmethod Danang Co., Ltd., a corporation having its registered office at 2F Ricco building, 363 Nguyen Huu Tho, Khue Trung Ward, Cam Le Dist., Da Nang, Vietnam

1.2. What is Personal Data?

In this Policy, “Personal Data” means information relating to a natural person, which is identified or identifiable, whether directly or indirectly, but excluding information of deceased natural persons. Please note that at all times we will adhere to the applicable statutory definition in determining what information is and is not Personal Data for the purposes of this Privacy Policy.

1.3. Scope of this Privacy Policy

This Privacy Policy applies to information, including Personal Data, which we collect in relation to your access or use of Our Services only. Regarding any information which you provide to or is collected by any third party other than us, please refer to privacy policy separately established by such third party.

1.4. Changes to this Privacy Policy

We will amend this Privacy Policy from time to time. We will notify you of the amendment of this Privacy Policy through Our Services, or other measures determined by us in case we make any substantive or material amendments. Any amendment will become effective upon our posting of the amended privacy policy on Our Services.

We collect the following information about you:

1) Information which you choose to provide to us through Our Services

• Profile Information: such as name, mailing address, phone number, email address, login name, login passwords, identification information (such as ID number, driver’s license number), birth date, gender, and photo

• Payment Information: such as credit card information, banking information, or information relating to other kinds of payment measure

• Information of Communication with us: such as information about the communications between you and us including your inquiry, compliments, and other contact to us

• Sensitive Personal Information: you may choose to provide us through Our Services with your information of a sensitive nature such as racial, ethnic origin, political opinions, cult, religious or philosophical beliefs, sexual behavior, criminal records, health data, disability, trade union information, genetic data, biometric data, or any other information of a sensitive nature. We do not collect and use these information without explicit consent from you, except where permitted by applicable laws.

2) Information collected as you use Our Services

• Usage Information: such as access dates and times, pages viewed, system activity, type of browser. In some cases, we collect this information through cookies, beacons, tags, and similar technologies that create and maintain unique identifiers.

• Device Information: such as information about the devices you use to access Our Services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages.

3) Information provided from third parties

• We may collect information about you to be provided from third parties due to your consent. For example, we may collect your payment information relating to your use of AWS Service provided by Amazon Web Services, Inc.

• In the event that we collect your Personal Data from a third party, we will notify you of the detail of the collected Personal Data and the detail of the third party. Such notification will be made within 30 days from the date of the collection.

3.1. We process your Personal Data for the following purposes, to the extent applicable.

• To provide Our Services
We process your Personal Data for providing you with Our Services. For example, we collect your name, email address, and other information to create an account of Our Services, and we use your user ID and password to verify you as a user of Our Services. If you use a chargeable service, we collect and use your payment information, such as banking account, credit card information, to charge you fees and other payment relating to Our Services.

• To maintain and improve Our Services
We process your Personal Data for maintaining or improving Our Services. For example, we collect and use information of trouble informed by you for tracking system failure and troubleshooting, or we collect and use your usage activity on Our Services for improving the functions of Our Services or develop more convenient for users.

• To develop new products or services
We process your Personal Data for developing new products or services. For example, we collect and utilize information of how you use Our Services, inquiry from you, or questionnaire result for developing new products or services.

• To provide ads
We will process your Personal Data for showing advertisings. We may also show you personalized ads based on your interests. For example, we collect information of your browsing of other website and utilize it for showing advertisings which you might be interested in. You can control what information we use to show you ads by settings.
- We don’t show you personalized ads based on Sensitive Personal Information.
- We don’t share information that personally identifies you with advertisers, such as your name or email, unless you ask us to.

• To measure and analyze performance
We process your Personal Data for analyzing and measuring how our services are used. For example, we measure and analyze your visits to and activity on Our Services for optimizing Our Services.

• To communicate with you
We use your Personal Data to communicate with you. For example, we respond to inquiries from you or may send you a notification about Our Services by using contact information provided by you such as email address. In addition, if you contact us, we will keep a record of your request in order to help solve any issues you might be facing.

• To protect us, our users, and the public
We may use your Personal Data to protect us, you or other users, or the public interest. For example, we use your account ID and password, device information, or activity data for detecting, preventing, and responding to unauthorized use of your account, fraud, abuse, security risks, and technical issues that could harm us, you, other users, or the public interest. We may also use your Personal Data to investigate or address claims or disputes relating to Our Services. Furthermore, we may use your Personal Data to prevent or suppress a danger to life, body, or health of any person if necessary.

• To comply with a law to which we are subjected
For example, we are required to keep a record of your Personal Data we collect for a certain period of time pursuant to applicable laws.

• To prepare historical documents or archives for public interest, or to research or statistics
For example, we may utilize your Personal Data to create and share with advertisers statistics in a form which does not personally identify you, such as usage activity on Our Services or the effectiveness of online advertising campaigns.

3.2. We will notify you or make announcement separately if the provision of your Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into an agreement, as well as the possible consequences of failure to provide such data.

4.1. We may share your Personal Data with the following categories of recipients:

• Our Affiliates
• Amazon Web Services, Inc., or other business partners having business alliance or inter-system collaboration with us
• third-party service providers performing services to help our operations, such as customer support, technical support, or customer management
• third-party IT service providers, such as provider of data storage service or business communication platform service
• third-party advertising service providers

4.2. Except for the recipients prescribed above, we will not disclose your Personal Data to any third party without your prior consent, except where we collected your Personal Data based on any of the legal basis prescribed in 5 below.

We process your Personal Data based on different legal basis depending on the nature of the Personal Data and the type of processing involved. We normally rely on necessity for performance of a contract or entry into a contract, or our or third-party’s legitimate interests to collect and use Personal Data. In some cases, we may rely on your consent for processing your Personal Data which is given to us. Details are shown below.

• Performance of a Contract / Entry into a Contract
Some of the Personal Data is processed on the basis that it is necessary for the performance of our agreement with you, or in order to take steps at your request prior to entering such an agreement. For example, we need to request you to provide your email address, login name, login passwords to create your account for using Our Services in order to perform our obligation under service agreement with you.

• Legitimate Interests
A second ground relied upon by us is that it is necessary for the purposes of legitimate interests pursued by us or a third party. These legitimate interests include the operation of Our Services and our business, maintenance and improvement of Our Services, pursuit of the safety of Our Services, such as fraud detection and prevention, charging the payment regarding the chargeable services, providing ads about Our Services or third-party’s services or products. Further examples are shown in 3. Why do we process your Personal Data? We will only rely on such a ground where such interests are not overridden by your interests or fundamental rights and freedoms.

• Research or Statistics / Preparation of Historical Documents or Archives for Public Interest
A third ground relied upon by us is that it is necessary for research or statistics, or preparation of historical documents or archives for the public interest. For example, we may create statistics relating to the business area to which our services belong for the purpose of our own or third-party’s marketing. We will only rely on such a ground where the suitable measures to safeguard your rights and freedoms are took in place and in accordance with applicable law.

• Compliance with a Law
A fourth ground relied upon by us is that it is necessary for compliance with a legal obligation. For example, we are required to retain records for fixed periods of time in order to comply with applicable laws.

• Prevention of a Danger / Performance of a Task for Public Interest
In some rare cases, there may be necessary for preventing or suppressing a danger to you or other person’s life, body, or health, or we may need to perform a task for the public interest.

• Consent
Finally, in certain limited situations, we rely on your consent in order to process your Personal Data. For example, we may use your location data in order to enable you to use more convenient functions of Our Services based on your consent, or we may collect information about you from a third party, such as username, photo, or other profile information stored in the third party, due to your consent when you log in Our Services through such third-party’s service, e.g. Facebook, Google, etc.'

6.1. We seek to take reasonable security measures to protect your Personal Data against loss, misuse, alteration, and divulgation. Such reasonable security measures include use of adequate security software, restricted access, and assigning a person in charge of managing Personal Data. However, please note that although we take appropriate steps to protect your Personal Data, no website, product, device, online application or transmission of information, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Data.

6.2. We store your Personal Data not only in Thailand but also in our data centers located in Singapore.

We retain your Personal Data until it is no longer necessary to fulfil the purposes of collecting your Personal Data, or until you request us to erase or destroy your Personal Data. We may be required to retain certain information in order to comply with the laws which we are subject to. Specific retention periods are determined based on the following considerations: purpose of collection or use, nature of the Personal Data, and the necessity of retaining the Personal Data for legal or business reasons. For example, if you are a user of Our Services, we will normally erase your Personal Data within [XX] months from the date on which you become no longer a user of Our Services; however, we may be necessary to retain the whole of part of your Personal Data for the purpose of establishment, compliance, or exercise of legal claims, defense of legal claims, or the purpose of compliance with the law.

Regarding your Personal Data which we collect and store, you have the rights to:

• request access to and obtain copy of your Personal Data
• receive your Personal Data or request us to send or transfer your Personal Data to other Data Controllers by the automatic means
• object the collection, use, or disclosure of your Personal Data
• request to erase, destroy, or anonymize your Personal Data
• request to restrict the use of your Personal Data
• request correction or update of your Personal Data
• withdraw the consent which you have given to us (your withdrawal of consent will not affect the lawfulness of procession made prior to such withdrawal)
• complain to expert committee with respect to our processing of Personal Data. If you are not satisfied with how we process your Personal Data, you may contact us through the Contact Detail below.

If you are located in the European Countries, you have certain rights and protections under General Data Protection Regulation (“GDPR”) regarding processing of your “personal data” as defined in the GDPR. Some of information that we process may constitute the “personal data”.

9.1. Our Role as a Controller or Processor

If you are located in one of the European Countries, we will act as a “controller” as defined in the GDPR when processing your personal data. We may also act as a “processor” as defined in the GDPR to the extent that we process your personal data on behalf of and at the instruction of another party.

9.2. Legal Basis of Processing

If you are located in the European Countries, we will collect and process your “personal data” based on the following legal basis:
• Performance of a Contract / Entry into a Contact
• Legitimate Interests
• Compliance with a Legal Obligation
• Protection of Vital Interests
• Performance of a Task for Public Interest
• Consent
Please refer to 5. The legal basis on which we process Personal Data for more details.

9.3. Automated Individual Decision-Making, Including Profiling

We will not use a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

9.4. Your Rights

If you are located in the European Countries, regarding your “personal data” which we collect and store, you have the rights to:
• access to your “personal data” and related information, such as categories of recipient, envisaged retention period, source of acquisition, and obtain a copy of your “personal data” in our possession

• rectify your inaccurate “personal data”

• erase your “personal data”

• restrict on processing of your “personal data”

• receive your “personal data” which you provided to us and request us to transmit those data to another controller (data portability)

• object to the processing of your “personal data”

• withdraw the consent which you have given to us at any time (your withdrawal of consent will not affect the lawfulness of procession made prior to such withdrawal)

• not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where:
Those rights may be subject to a certain conditions as set forth in the GDPR.

9.5. Data Transfers

We will transfer your “personal data” to any of our Affiliates or third-party service providers outside of the European Countries. When we transfer your “personal data” to such entity outside of the European Countries, we ensure that appropriate safeguards and protections are took in place pursuant to the GDPR. For example, we enter into agreements including standard data protection clauses adopted by the European Commission or other appropriate arrangements with various entities located outside the European Countries with whom we share your “personal data”. However, please acknowledge that some countries that we transfer your “personal data” might not have appropriate safeguards and protections under the GDPR. If we transfer your “personal data” to any of such countries, we will notify you of the possible risks of such transfer for you due to the absence of an appropriate safeguards and obtain your consent with such transfer. If you wish to receive a copy of documentation related to these safeguards, please contact us.

9.6. Complaints

If you are located in one of the European Countries, you may file a complaint with the Data Protection Supervisory Authority of the Member State of your habitual residence, place of work, or place of the alleged infringement.